UNIVERSITY OF PITTSBURGH POLICY 11-01-03
CATEGORY: RESEARCH ADMINISTRATION
SECTION: Research
SUBJECT: Conflict of Interest - Research/Teaching
EFFECTIVE DATE: June 21, 1996 (Revised April 4, 1997)
PAGE(S): 10
I. INTRODUCTORY NOTE
In recent years many University faculty have taken on functions
outside their traditional domain of teaching and scholarship.
Technology transfer and public service involvement of various
kinds are encouraged by the government and seem necessary for the
public good. There is the potential for good as well as for
serious conflicts of interest to emanate from such endeavors.
The federal government presently regulates conflicts of interest
pertaining to government grants by requiring that universities
maintain a written policy in the area.* This policy is
consistent with those regulations.**
Regular and timely full disclosure of potential conflicts is at
the heart of the policy. The most difficult conflicts of
interest in research arise not because of a clash of "good versus
evil," but often because of a clash of "good versus good." Two
desirable outcomes, or the procedures necessary to achieve such
outcomes, cannot always be reconciled. On the other hand, when
outcomes or procedures appear clearly wrong and they are in
conflict with generally accepted values, commitments, or norms,
the solution is much simpler. The wrongful behavior should be
stopped immediately. Formulating policies and procedures to
manage, reduce, or eliminate potential or real conflicts of
interest (or conflicts of commitment) among faculty,
administrators, or investigators requires that the University
delineate the value structure to which it and its faculty,
administrators, and investigators must adhere. Fortunately,
these values and professional norms are not difficult to
state.***
Faculty, administrators, and investigators are expected to share
a commitment to at least these values:
- a genuine commitment to teaching and research and to the
institution
- academic freedom
- intellectual independence
- diversity
- open communication and dissemination of knowledge
- competence and integrity in research and education
- public service
- serving as examples to society
Given such commitments, there can, from time to time, be
conflicts among them generated by the activities of faculty,
administrators, and investigators who seek to advance their
scholarly work and themselves. This document deals primarily
with conflicts of interest while conflicts of commitment are
mentioned only when they result from or have a bearing on a
conflict of interest.
The following examples illustrate potential or actual conflicts
of interest:
1. Accepting gratuities or special favors related to teaching,
research, or administrative duties.
2. Giving well paid lectures for companies or organizations
whose economic or political interests are affected by an
investigator's scholarly work.
3. Undertaking evaluative research when the investigator or the
investigator's dependents have a financial, managerial, or
ownership interest in the sponsoring company or in the
company producing the product tested.
4. Entering into a paid consultantship arrangement with an
organization or individual having an economic interest in
related research.
5. Using students or employees of the institution to perform
services for a company in which a faculty member has an
ownership interest or from which he/she receives any type of
remuneration.
6. Assigning as required texts in their course, books for which
the instructor derives significant financial benefits.
7. Accepting support for research under terms and conditions
that results be held confidential, unpublished, or
significantly delayed in publication.
8. Providing privileged access to information, developed with
University resources or supported by independent sponsors,
to an entity in which the faculty member, investigator, or
administrator has a political or financial interest.
9. Purchasing equipment, instruments, or supplies for research
or teaching from a firm in which the faculty member,
investigator, or administrator has a financial or other
interest.
10. Influencing the negotiation of contracts between the
academic institution and outside organizations with which a
faculty member, investigator, or administrator has a
financial interest or other relationship.
The above examples are by no means exhaustive, but they are
exemplary of potential conflicts of interest that must be
disclosed, forsworn, or otherwise managed, reduced, or eliminated
prior to the materializing of the conflict.
The University will require timely, full, and mandatory
disclosure of faculty's, administrators', or investigators'
outside relationships and organizational commitments to identify
and manage, reduce, or eliminate any conflicts. Full and timely
disclosure by faculty, administrators, or investigators will
sensitize them, chairs, and deans to potential conflicts of
interest and promote management, reduction, or elimination of
actual conflicts.
The University will develop awareness of the Conflict of Interest
Policy and Procedures in several ways:
1. Presentations to all department chairs and deans;
2. Publication of the policy and procedures in the Policy and
Procedures Manual of the University and dissemination to all
current faculty, investigators, and administrators at
departmental meetings where a discussion will be held about
the policy and procedures;
3. Incorporation of an explanation of the policy and
procedures, including their importance, mechanisms, and
standards, into the orientation program for new faculty, and
at the time of annual review of faculty performance;
4. Emphasis by deans and department chairs of the need for
consistent and equitable adherence to the policy and
procedures by all deans, department chairs, faculty,
administrators, and investigators;
5. Faculty participation through the University Senate
representatives on the Conflict of Interest Committee; and
6. Monitoring by the Conflict of Interest Committee.
The policy assures that potential conflicts routinely come to the
attention of department chairs and deans, who have historically
settled such issues and will continue to do so in most cases.
However, the policy does not and cannot have explicit
prescriptions for all acceptable and unacceptable conflicts.
Potential conflicts that do not yield to settlement attempts by
the deans and department chairs, will be passed on to the Senior
Vice Chancellors who may seek guidance from the Conflict of
Interest Committee.
It is the task of the Conflict of Interest Committee to
investigate novel or difficult situations in light of the general
guidelines of the Conflict of Interest Policy and federal
regulations in order to provide the referring Senior Vice
Chancellor with the best impartial and informed advice.
The Chair of the Conflict of Interest Committee, appointed by and
reporting to the Chancellor of the University, shall work closely
with the academic administrators in ensuring procedural
compliance with the Conflict of Interest Policy and associated
government regulations. The Chair of the Conflict of Interest
Committee shall make or supervise all contacts with government
agencies or other outside parties and shall maintain a record of
all proceedings.
The Conflict of Interest Committee will review and recommend
revisions to the Conflict of Interest Policy as appropriate.
II. GENERAL PRINCIPLES
- Recognition that not all conflicting interests are
necessarily impermissible.
- Reliance on complete, timely disclosure. Disclosure, but
not necessarily prohibition, of financial interests and
remunerations, where applicable.
- Case by case analysis.
- Accountability at all levels of review -- up to and
including the Chancellor.
- Assurance of confidentiality (save for disclosure to
superiors within a structure of accountability and to
federal funding agencies when required under terms of the
grant, contract, or cooperative agreement).
- Timely, but not less than annual, review and analysis of
conflicts managed, reduced, or eliminated.
III. DEFINITIONS, POLICY,**** AND GUIDELINES
In general, conflicts of interest relate to the potential for
self-gain usually, but not always, of a fiscal nature. Potential
for self-gain might serve to undermine the judgment or
objectivity of faculty, administrators, or investigators such
that their primary mission and dedication to academic values and
activities of the University are compromised. Furthermore, not
only bias, but the appearance of bias in research, may undermine
public trust in the University.
The opportunity for investigators or scholars to receive
financial or other personal rewards from their endeavors is not
intrinsically unacceptable, as long as it does not adversely
affect the objectivity, integrity, or professional commitment of
an investigator. Hence, participation in a situation with
opportunity for personal gain does not constitute an unacceptable
situation of itself; it is the potential stimulus for
unacceptable behavior that must be addressed.
A. Definitions
1. Conflict of Interest*****
A potential or actual conflict of interest exists when
commitments and obligations to the University or to
widely recognized professional norms are likely to be
compromised by a person's other interests or
commitments, especially economic, particularly if those
interests or commitments are not disclosed. Federal
Regulations provide that a conflict of interest exists
if the reviewer(s) of disclosures determines that a
significant financial interest could "directly and
significantly affect the design, conduct, or reporting"
of federally funded activities.
2. Members of the Immediate Family
Dependents, the spouse, and all members of the
household are considered members of the immediate
family. Circumstances or relationships that must be
disclosed or managed, reduced, or eliminated as to a
faculty member, administrator, or investigator usually
must also be disclosed or managed, reduced, or
eliminated if the faculty member, administrator, or
investigator knew or should have known that a member of
his or her immediate family had such a relationship.
3. Administrators
"Administrators" in the context of this document
includes all administrative employees, even if they do
not hold faculty rank, who direct or can materially
influence research.
4. Investigators
Investigators includes all employees who are
responsible for the design, conduct, and reporting of
research.
B. Policy
1. Faculty members, administrators, and investigators are
required to make regular, timely, and full confidential
disclosures to their superior, using the disclosure
form(s) included with this policy. This will generally
include disclosure of all outside remunerative
activities related to their teaching, research, or
administrative responsibilities. They must also
disclose equities and positions of members of their
immediate family which could create a conflict or the
perception of a conflict of interest between their
academic obligations and their outside interests.
2. The Conflict of Interest Policy also imposes the
obligation on department chairs, and other supervisory
administrators -- themselves subject to the policy and
its disclosure requirements -- not to encourage or
condone impermissible conflicts on the part of their
faculty, administrators, or investigators.
3. Sanctions may be applied for non-compliance with the
requirements or provisions of this policy in the same
way as for non-compliance with any other University
policy, including removal from the particular project,
letter of reprimand, special monitoring of future work,
probation, suspension, salary reduction, or initiation
of steps leading to possible rank reduction or
termination of employment.
C. Guidelines
1. Obligations
A person who accepts a regular appointment to the
faculty, the administration, or to a research position
has an obligation to devote his/her primary
professional effort to the University to the extent
required by the appointment or research position.
Other activities or commitments must be arranged so as
not to conflict with or dilute this commitment. While
employment outside the contract period (i.e., summer
employment) may not represent a conflict of commitment,
it can generate a conflict of interest.
2. Confidentiality
In order to encourage full disclosure of potential
conflicts without unduly intruding on the privacy of
University personnel or their families, disclosures
shall be treated confidentially and disclosed only to
the extent necessary for review, to consider and
manage, reduce, or eliminate any conflicts, and to
comply with requests from federal funding agencies made
in accordance with the terms of the grant, contract, or
cooperative agreement.
3. Subsequent Disclosure
Financial, personal, or professional relationships that
raise a potential conflict of interest or its
perception shall be fully and accurately disclosed in
all formal communications relating to the sponsored
research, including those in professional journals.
4. Withdrawal from Decisions
Faculty, administrators, and investigators shall not
exercise decision-making authority or exert influence
concerning any University relationship affecting a
company in which they or members of their immediate
family have a personal or professional interest.
5. Technology Transfer
The commercialization and the transfer of technology
can create conflicts of interest. Rules pertaining to
technology transfer are published in the University
Technology Transfer Policy (11-02-01).
D. Encouraging Openness and Exchange of Information
1. The free exchange of information is a fundamental value
underlying the University's mission. Faculty,
administrators, and investigators have the general
right to know the nature, purposes, methods, results,
and sponsorship of relevant research conducted within
the University.
2. In order to avoid broad limitations on collegial
communication, arrangements involving the receipt of
confidential scientific information, which may not be
shared with colleagues reasonably promptly, shall be
kept to a minimum. Where such arrangements are
unavoidable, the scope of the project shall be defined
so as to permit the exchange of as much information as
possible.
3. Insofar as possible and in accordance with the
University Research Integrity Policy (11-01-01),
University guidelines on externally sponsored research,
and the University Technology Transfer Policy (11-02-
01), all significant results of research shall be
published or publicly disclosed with reasonable
promptness whether the results are favorable or
unfavorable to the interests of any sponsor. Certain
restrictions or limited delays in dissemination of
information may be warranted by scientific prudence,
the need to prepare patent applications, other legal
rights, or for other justifiable reasons.
E. Assignment of Students and Staff
1. Staffing of sponsored research is subject to University
policies, and sponsors may not interfere with staffing
decisions.
2. Students and post-doctoral fellows shall not be
exploited or their education compromised in the service
of sponsored research or the financial gain of the
supervisor. Employment of students or fellows by
companies in which their faculty supervisor has
economic interests must be disclosed on Part II of the
Disclosure Form by the student's academic supervisor.
3. Faculty shall take all precautions necessary to ensure
that their students' progress and academic standing are
not jeopardized by violations of any professional norms
in projects in which they participate, or by students'
naivete as to the circumstances surrounding
industrially sponsored research.
F. Compensation to Clinical Investigators
Compensation arrangements for support of clinical studies
shall not adversely affect the conduct or influence the
outcome of clinical research.
IV. PROCEDURES
Disclosure of outside interests and commitments by faculty
members, administrators, and investigators to their chairs,
deans, or direct higher level supervisors shall be made upon
appointment and each April 15 thereafter or when a conflict
arises during the year. In special situations, a faculty member,
administrator, or investigator may request that the dean (rather
than the department chair) provide the initial review of the
information disclosed. The dean will then rule whether the
information must also be disclosed to the department chair.
If chairs or other superiors perceive that they have a "conflict
of interest" in reviewing disclosed information, they shall
disqualify themselves and request that the review be done by
their superiors.
Review after disclosure must take place promptly and help
faculty, administrators, and investigators determine which
interests are not in conflict, which conflicting interests may be
permissible, and which conflicting interests place the faculty
member, administrator, or investigator at risk of jeopardizing
the integrity of his/her academic or administrative work.
The choice of full disclosure in place of categorical
prohibitions is based on the assumption that once a conflict is
recognized, it can be avoided or managed, reduced, or eliminated.
Disclosures shall be kept confidential, except to the extent
necessary to review, consider, and manage, reduce, or eliminate
any conflicts. The conflict of interest definition, guidelines,
and procedures shall be read and interpreted at all times in
coordination with the University Research Integrity Policy (11-01-
01), the Policy on Outside Professional Service (02-06-01), the
Technology Transfer Policy (11-02-01), Continuing Medical
Education guidelines, and other relevant policies.
A. Faculty Members, Administrators, and Investigators
1. Every faculty member, administrator, and investigator
must complete on an annual basis the Statement of
Outside Interests and Activities (Part I of Disclosure
Form) and submit it on or before April 15 or when a
conflict arises during the year to his/her supervisor;
i.e., the department chair or dean, as appropriate. If
in the judgment of the faculty member, administrator,
or investigator a potential or actual conflict arises,
the Disclosure Form shall be updated promptly. The
superiors receiving these forms are required to keep
them in a secure place for at least three years after
the filing of the final financial reports of relevant
funded projects or longer if required by the funding
agencies.
2. Every faculty member, administrator, and investigator
must submit a current copy of the Statement of Outside
Interests and Activities to the department chair or
dean with each proposal for research funding. A
current copy of Part I should remain in the Office of
Research for at least three years after the filing of
the final financial reports of relevant funded projects
or longer if required by the funding agencies.
3. As required by the University policy on outside
professional service, faculty members, administrators,
and investigators shall also discuss, prospectively,
with their superiors any planned outside interests and
activities that have the potential to conflict with,
could appear to be in conflict with, or are in conflict
with their commitment to the University or to their
research for the purpose of managing, reducing, or
eliminating the potential or actual conflict.
B. Department Chairs or Deans
1. The chairs or deans, as the case may be, shall maintain
in confidence all Statements of Outside Interests and
Activities submitted to them by faculty members,
administrators, and investigators, except for the
disclosure which is authorized by this Conflict of
Interest Policy.
2. They shall:
a. review all faculty's, administrators', and
investigators' Statements of Outside Interests and
Activities for real, apparent, or potential
conflicts of interest; and request and document
additional details including precise dollar
figures for ownership interests or remuneration if
such details appear necessary for a sound
determination of the presence or absence of an
impermissible conflict of interest;
b. notify their superiors and the Chair of the
Conflict of Interest Committee of the fact that
specific faculty members, administrators, or
investigators have outside interests, based on
affirmative answers in Part I of the Disclosure
Form and additional details in Part II of the
Disclosure Form;
c. determine whether their superiors wish to review
the detailed information of outside interests
provided by faculty members, administrators, or
investigators and, if so, notify them that the
superior will be reviewing the Disclosure Form
they have submitted;
d. meet with individual faculty, administrators, or
investigators to discuss collegially how potential
or actual conflicts shall be managed, reduced, or
eliminated;
e. recommend and initiate action to manage, reduce,
or eliminate the apparent, potential, or real
conflict within 60 days of disclosure or refer it
to the next higher level; and
f. recommend and initiate action leading to sanctions
for non-compliance with proposed management,
reduction, or elimination of a conflict.
3. Any faculty member, administrator, or investigator who
disagrees with the recommendation of his/her superior
for managing, reducing, or eliminating conflicts of
interest may appeal to the next higher level of
administration as specified below. As a second step,
the grievance procedure of the Faculty Handbook may be
followed.
4. Department chairs, deans, other administrators, or the
Senior Vice Chancellors may demand disclosure by
faculty, administrators, and investigators of all
outside income related to professional
responsibilities, regardless of any threshold amount
specified in the Statement of Outside Interests and
Activities.
5. The enforcement of this policy on conflict of interest
rests primarily with the academic unit where the
research is conducted. The immediate supervisor of the
faculty member, administrator, and investigator should
be cognizant of the activities taking place in the unit
and should monitor the research as to potential and
actual conflicts of interest. Reviews conducted by the
supervisor, as appropriate but no less than annually,
should contain questions probing the conflict of
interest issue. The listing given in the Introductory
Note of the policy highlights some conflict of interest
areas of concern. Some examples of appropriate actions
to resolve conflicts of interest are:
a. Public disclosure of significant financial
interests in publications and presentations.
b. Monitoring of research by independent reviewers.
c. Modification of the research plan.
d. Disqualification from participation in all or a
portion of the funded research.
e. Divestiture of significant financial interests.
f. Severance of relationships that create actual or
potential conflicts.
6. In the event that a conflict of interest related to a
federally funded project is identified after the
project is underway, the immediate supervisor of the
faculty member, administrator, or investigator shall
notify the Chair of the Conflict of Interest Committee
of the conflict who will report to the federal agency
within 60 days that a conflict exists and action is
being taken to manage, reduce, or eliminate the issue.
C. Annual Summary Reports
1. The department chairs and deans, as the case may be,
shall submit an annual report of largely anonymous data
to their respective superiors and the Chair of the
Conflict of Interest Committee by December 31 of each
year. These data shall include the following:
a. the number and percentage of department faculty,
administrators, and investigators who have had to
submit detailed Statements of Outside Interests
and Activities (Part II);
b. concerning each question on the Statement of
Outside Interests and Activities, the number and
percentage of department faculty, administrators,
and investigators who have affirmatively answered
each question;
c. the number and percentage of department faculty,
administrators, or investigators whose outside
interests and activities were found to be in
conflict with their University and/or professional
commitments, and whose conflicts were managed,
reduced, or eliminated;
d. the number and percentage of any faculty's,
administrators', or investigators’ conflicts of
interest which were not managed, reduced, or
eliminated; and
e. details regarding remedial action recommended and
taken.
2. The deans or directors of all units shall be
responsible for submitting an annual review of the data
summary of their unit’s Statements of Outside Interests
and Activities to their Senior Vice Chancellor for
independent or collaborative evaluation of the unit’s
outside interests and activities that present real,
apparent, and/or potential conflicts of interest. The
deans have the right and authority to request from the
department chairs the complete Statement of Outside
Interests and Activities of any faculty member,
administrator, or investigator within the respective
schools.
D. Review Procedure
1. At the request of the faculty members, administrators,
investigators, or department chairs within their
schools, the deans evaluate the recommendations made by
the chairs and decide whether additional or different
action is necessary to prevent, manage, reduce, or
eliminate conflicts of interest. If the faculty
member, administrator, investigator, or department
chair is still dissatisfied with the determination of
the dean regarding a potential conflict of interest,
the faculty member, administrator, investigator, or
department chair may request the dean to present the
matter to the Senior Vice Chancellor for the Health
Sciences or to the Provost's Office for review,
consideration, and recommendation of action to prevent,
manage, reduce, or eliminate the conflict in a timely
fashion after receiving the request.
2. The Provost of the University has the ultimate
authority to determine how conflicts of interest should
be prevented, managed, reduced, or eliminated and to
approve sanctions for non-compliance with proposed
management, reduction, or elimination of conflicts.
The Provost may utilize the assistance of the Conflict
of Interest Committee in arriving at decisions.
________________
*It should be noted that this policy covers Conflicts of Interest on
research/teaching issues as distinguished from the policies on
Conflict of Interest for Consultants, Conflict of Interest for
Designated Administrators and Staff, and the Conflict of Interest and
Procurement Relationships.
**National Science Foundation Grants Policy Manual - Investigator
Financial Disclosure Policy, October 1, 1995, and Public Health
Service Regulations codified at 42 CFR Part 50, and 42 CFR Part 94.
***Some of the language of this discussion has been taken from the
"Guidelines for Dealing with Faculty Conflicts of Commitment and
Conflicts of Interest in Research" by the Association of American
Medical Colleges, Copyright 1990, ACM Washington, DC.
****This policy is a generalized and abbreviated version of the
proposal by the Conflict of Interest Committee, University of
Pittsburgh, Health Sciences Schools, with amendments by the University
Research Council and the TAF Senate Committee. Some of the language
of the proposal and of this policy has been taken from the "Guidelines
for Dealing with Faculty Conflicts of Commitment and Conflicts of
Interest in Research" by the Association of American Medical Colleges,
Copyright 1990, ACM Washington DC. The policy is accompanied by an
Introductory Note that presents examples and background.
*****Conflicts of Interest in Academic health Centers: Policy Paper
#1. Association of Academic Health Centers, Washington, DC: 1400
Sixteenth Street, NW, Suite 410, Washington, DC 20036 (1990). These
definitions of conflict of interest and the guidelines stated below
were formulated in 1990 by the Association of Academic Health Centers.
The definition and guidelines are being used with the permission of
the Association. Some revisions have been made to adapt the language
of the definition and guidelines to the University of Pittsburgh.
CONFIDENTIAL
University of Pittsburgh disclosure form for calendar year 2002
FOR RESEARCHERS AND TEACHERS
(University Policy 11-01-03)
http://www.pitt.edu/HOME/PP/policies/11/11-01-03.html
PART I
Only those outside interests related to University activities need to
be reported. Not all outside interests and financial relationships
place the faculty member, administrator, or investigator in conflict
with each person’s obligations to the University and to his or her
profession. Not all conflicting interests are necessarily
impermissible. Timely and complete disclosure of potential conflicts
of interest protects you from suspicion and accusations of breach of
academic integrity.
STATEMENT OF OUTSIDE INTERESTS AND ACTIVITIES
NAME ______________________________ DATE _________________________
(Please type or print clearly.)
SCHOOL ____________________________ DEPARTMENT ___________________
(e.g., Engineering, Nursing, etc.)
CAMPUS ADDRESS/PHONE _________________________________________________
Purpose:
The purpose of this disclosure statement is for faculty members,
administrators, and investigators of the University to ensure that no
unresolved conflict exists between their primary University
commitments and their outside interests and activities. This
statement conforms with current federal guidelines requiring
disclosure for professional activities of faculty members,
administrators, and investigators. This statement establishes
specific facts to help supervisors (e.g., the department chairs,
deans, Senior Vice Chancellor for Health Sciences or the Provost) to
determine whether a potential conflict exists so that they may manage,
reduce, or eliminate the problem.
Procedure:
All faculty members, administrators, and investigators must complete
this form annually and submit it to their department chair or dean for
review and approval. All Part I declarations must be submitted to the
Office of Research on or before April 15. Part II declarations, where
required, must be submitted, with corresponding management plans, to
the Senior Vice Chancellor for Health Sciences or Provost by May 15.
In addition, faculty and other professional employees who conduct or
administer research supported by external funds must submit a current
copy of Part I and, if applicable, Part II of this form to their
department chair or dean, as appropriate, with each proposal for
funding and when they believe new facts create a potential or actual
conflict of interest.
1. Ownership Interests
During the past calendar year, did you or members of your
immediate family,* own or control an equity interest in any
organization** in your field of academic interest or
specialization that when aggregated for you, your spouse and
dependent children exceeded a 5% ownership interest or is greater
than $10,000?
YES _____ NO _____
2. Offices and Positions
During the past calendar year, were you or a member of your
immediate family, a director, officer, partner, employee, or
agent, or in any managerial position in any organization outside
the University of Pittsburgh that might be affected by your
research or administrative activities? You need not answer with
respect to governmental committees, community, political,
academic, charitable, religious, social or professional nonprofit
organizations.
YES _____ NO _____
3. Remunerative Activities
Does income (cash or in-kind, other than reimbursement of
reasonable expenses) related to your teaching, research, or
administrative activities received by you during the past year or
expected over the coming year from any one organization outside
the University exceed 1% of your University salary or does income
aggregated for you, your spouse, and dependent children received
from such an organization during the past year or expected over
the coming year exceed $10,000? (NOTE: UPP members do not need
to report practice plan salary.)
YES _____ NO _____
4. Outside Employment of Students or Staff
Do you now, or did you during the past calendar year, employ any
of your students or staff in a company or organization outside
the University?
YES _____ NO _____
5. Technology Transfer Activities
Are you or a member of your immediate family the inventor of any
technology for which an invention disclosure has been filed or
which is being developed or evaluated in connection with your
research activities?
YES _____ NO _____
6. Other Transactions or Facts
During the past calendar year, did you or any member of your
immediate family have an interest in any contract, sale, or other
transaction to which the University of Pittsburgh or one of its
affiliates was a party, or are there other situations, not listed
above, that you believe may create an actual or perceived
conflict of interest? (Exclude your own or your spouse’s
employment contract with the University.)
YES _____ NO _____
I have reviewed the Conflict of Interest Policy for Researchers and
Teachers and attest that I have made a complete and accurate statement
of my reportable outside interests and activities. Furthermore, I
understand and accept my obligation to disclose, in a timely fashion,
any subsequent change in financial interest status which may present
the potential for perceived conflict of interest according to
University policy.
NAME ______________________________ DATE _________________________
(Please type or print clearly.)
SIGNATURE ____________________________________________________________
PLEASE NOTE: Sanctions may be applied for non-compliance with the
requirements or provisions of this policy in the same way as for non-
compliance with any other University policy, including removal from
the particular project, letter of reprimand, special monitoring of
future work, probation, suspension, salary reduction, or initiation of
steps leading to possible rank reduction or termination of employment.
Supervisor’s Statement
___ I certify that the person named above reports to me and to the
best of my knowledge has made full disclosure, does not have any
conflicts of interest, and does not need to file a Part II
declaration.
OR
___ I certify that the person named above reports to me, has made a
full disclosure, and has filed a Part II declaration.
NAME _______________________________ TITLE _______________________
(Please type or print clearly.)
SIGNATURE __________________________ DATE ________________________
======================================================================
IF YOU ANSWERED “YES” TO ANY OF THE QUESTIONS OF PART I, YOU MUST
COMPLETE THE RELEVANT SECTIONS OF PART II.
======================================================================
* Dependents, the spouse, and all members of the household are
considered members of the immediate family.
** “Organization” includes any corporation, partnership,
proprietorship, firm, enterprise, franchise, association, trust,
government agency, or other entity but does not include mutual funds
over which you have no control.
COMPLETE PART II ONLY IF YOU ANSWERED “YES” TO ANY QUESTIONS IN PART I
University of Pittsburgh disclosure form for calendar year 2002
FOR RESEARCHERS AND TEACHERS
PART II – CONFIDENTIAL DISCLOSURES
Detailed Statement of Outside Interests and Activities
NAME ______________________________ DATE _________________________
(Please type or print clearly.)
SCHOOL ____________________________ DEPARTMENT ___________________
(e.g., Engineering, Nursing, etc.)
1. Ownership Interests
If, during the past calendar year, you or members of your
immediate family* owned or controlled (in aggregate) an equity
interest in any organization** in your field of academic interest
or specialization that exceeded a 5% ownership interest or is
greater than $10,000, give details below.
City & Nature of Relationship of
Organization State Business Family Member
2. Offices and Positions
Please give details if, during the past calendar year, you or a
member of your immediate family, were a director, officer,
partner, employee, or agent, or in any managerial position, in
any organization outside the University of Pittsburgh that might
be affected by your research or administrative activities. (You
need not include governmental committees, community, political,
academic, charitable, religious, social or professional nonprofit
organizations.)
Nature of Relationship of
Organization Position Business Family Member
3. Remunerative Activities
Please give details of income (cash or in-kind, other than
reimbursement of reasonable expenses) related to your teaching,
research or administrative activities received by you during the
past year or expected over the coming year from any one
organization outside the University exceeding 1% of your
University salary. Please also give details of income aggregated
for you, your spouse, and dependent children received from any
one organization outside the University during the past year or
expected over the coming year exceeding $10,000.
Remunerative Code
Organization Nature of Business – A, B or C*
*Remunerative Code: A = exceeds $10,000, B = exceeds 1% of
salary, C = exceeds both
4. Outside Employment of Students or Staff
Please give details if you now, or during the past calendar year,
employed any of your students or staff in a company or
organization outside the University.
Effort
Staff or Student Name Employer (Hours/Year)
5. Technology Transfer Activities
If you answered YES to the the Technology Transfer question in
Part I, please give a brief description of the technology in
which you have an interest and any license agreements or other
technology transfer agreements entered into for that technology.
Even if you have not yet received any financial remuneration for
the technology, please list those agreements for which you would
be entitled to share in commercial proceeds under University of
Pittsburgh or other institutions’ technology transfer policies.
6. Other Transactions or Facts
Please give details if during the past calendar year you or any
member of your immediate family had an interest in any contract,
sale or other transaction to which the University of Pittsburgh
or one of its affiliates was a party. In addition, if there are
other situations, not covered in questions 1-5 above that may
create an actual or perceived conflict of interest, please
explain? (Exclude your own or your spouse’s employment contract
with the University.) Please identify such transactions or
facts, including date, parties, subject matter, etc.
I attest that the above is an accurate and current statement of all my
reportable outside interest and activities.
NAME ______________________________ DATE _________________________
(Please type or print clearly.)
SIGNATURE ____________________________________________________________
Supervisor’s Statement
___ I certify that the person named above reports to me and to the
best of my knowledge has made full disclosure. I have reviewed
this form, discussed the contents with the individual and find no
reason for further action. This form (Part II only) and other
supporting information will be forwarded to the Dean/Campus
President for further review. (Part I must be sent to the Office
of Research.)
OR
___ I certify that the person named above reports to me. The
individual and I have been unable to reach a satisfactory
resolution of their potential conflict of interest. I am
forwarding this form (Part II only) along with supporting
information to the Dean/Campus President for his/her
adjudication. (Part I must be sent to the Office of Research.)
NAME _______________________________ TITLE _______________________
(Please type or print clearly.)
SIGNATURE __________________________ DATE ________________________
Please note: All Part II disclosures and supporting material are
forwarded to the Dean or Campus President and then to the Provost or
Senior Vice Chancellor for the Health Sciences for their reviews and
then are placed in a confidential database. The information will be
treated confidentially and disclosed only to the extent necessary for
review, to consider and manage, reduce, or eliminate any conflicts,
and to comply with requests from federal funding agencies made in
accordance with the terms of the grant, contract, or cooperative
agreement.
Furthermore, sanctions may be applied for non-compliance with the
requirements or provisions of this policy in the same way as for non-
compliance with any other University policy, including removal from
the particular project, letter or reprimand, special monitoring of
future work, probation, suspension, salary reduction, or initiation of
steps leading to possible rank reduction or termination of employment.
* Dependents, the spouse, and all members of the household are
considered members of the immediate family.
** “Organization” includes any corporation, partnership,
proprietorship, firm, enterprise, franchise, association, trust,
government agency, or other entity but does not include mutual funds
over which you have no control.
Revised: September 2001 Policy 11-01-03
Conflict of Interest in Research/Teaching
ANNUAL DATA SUMMARY REPORT
STATEMENT OF OUTSIDE INTERESTS AND ACTIVITIES
For All Faculty
(And non-faculty employees responsible for the conduct, design,
direction, or reporting of research)
for calendar year 2002
School: ___________________________________
Department: _______________________________
Number
Total number of disclosures submitted (Part I) ______
Number who have had to submit detailed Statements of
Outside Interests and Activities (Part II) ______
Number who affirmatively answered each of the
following:
Question 1 (Ownership Interests) ______
Question 2 (Offices and Positions) ______
Question 3 (Remunerative Activities) ______
Question 4 (Outside Employment of Students or Staff) ______
Question 5 (Technology Transfer Activities) ______
Question 6 (Other Transactions or Facts) ______
Number whose outside interests and activities were
found to be in conflict with their University and/or
professional commitments, but which conflicts were
resolved ______
Number whose outside interests and activities were
found to be in conflict with their University and/or
professional commitments, but which conflicts were NOT
resolved ______
- Departmental forms should be submitted to the Office of the Dean,
Director, or Campus President for inclusion in the unit totals.
- A summary report for the entire unit should be submitted by May
15 to the Office of the Provost, 826 CL.
Report Prepared By _______________________ Date _______________
UNIVERSITY OF PITTSBURGH POLICY 11-01-03
Conflict of Interest - Research/Teaching
CONFLICT OF INTEREST MANAGEMENT REPORTING FORM – Calendar 2002
This form should be completed by the dean or campus president, as
appropriate, for each faculty or staff member who declared they have
outside interests (i.e. those who gave affirmative answers to
questions in Part I of the Statement of Outside Interests and
Activities Disclosure Form and were required to provide explanatory
information in the Part II Disclosure Form). This form, along with
copies of the Part II Disclosure Form (and other pertinent documents)
is to be forwarded to the Provost or Senior Vice Chancellor for Health
Sciences as appropriate.
1. Name of Disclosing Faculty/Staff
___________________________________________________
2. Name of Primary Administrative Reviewer(s) (Department Chair,
Division Head, etc. if applicable)
___________________________________________________
3. Brief description of the disclosed interest from Part II:
a. Ownership interest
___________________________________________________
b. Offices/Positions
___________________________________________________
c. Remunerative Activities
___________________________________________________
d. Outside employment of Pitt students or staff
___________________________________________________
e. Technology Transfer Activities
____________________________________________________
f. Other Transactions or Facts
___________________________________________________
4. Do you have interests that may interfere or appear to interfere
with your ability to provide an unbiased review of this
faculty/staff member’s disclosure?
YES / NO
If YES, forward the Part II Disclosure Form and an explanation
to the Provost/Senior Vice Chancellor for review and action.
5. Is simple disclosure alone sufficient to manage the outside
interest(s)?
YES / NO
If YES, please briefly explain your thinking.
If NO, please append a detailed description of the measures
that were (or will be) taken to successfully manage the
situation. Include a description of ongoing follow-up or
monitoring if appropriate.
6. Do you consider this case satisfactorily resolved?
YES / NO.
If NO, please schedule an appointment with the Provost/Senior
Vice Chancellor for discussion and further action.
________________________________ ______________ ______________
Signature of Dean/Campus President School/Campus Date
NOTE: You should inform the faculty that this information will be
forwarded for review to the Provost or Senior Vice Chancellor
for Health Sciences as a matter of routine and that it will be
maintained in a confidential, centralized database.